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Supreme Court of India 2020-03-03 allowed

K. Virupaksha & Anr vs The State of Karnataka & Anr

Bench: 3 — R. Banumathi, S. Abdul Nazeer, A.S. Bopanna

In Brief

Canara Bank officers (appellants) were accused of defrauding a borrower by not fully disbursing a loan and allegedly colluding in undervalued auction of pledged property. After the borrower exhausted writ petitions and debt recovery tribunal proceedings without success, he filed a criminal complaint. The Supreme Court quashed the FIR against the bank officers, holding that such disputes fall within SARFAESI Act's exclusive regulatory framework which provides comprehensive remedies before debt recovery tribunals. Filing a criminal complaint on identical grounds after failing in civil remedies constitutes abuse of process and harassment. Criminal law should not be invoked to relitigate regulatory matters already adjudicated by specialist courts.

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Criminal Procedure Abuse of Process SARFAESI Act Banking Law Secured Creditors Debt Recovery Writ Jurisdiction Criminal Quashing

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